ACIT Vs Viacom 18 Media Pvt. Ltd (ITAT Mumbai)
The appeal and cross-objection before the Income Tax Appellate Tribunal (ITAT) Mumbai arose from the order of the National Faceless Appeal Centre (NFAC)/Commissioner of Income Tax (Appeals), Delhi, dated 27 August 2024, for Assessment Year (AY) 2014–15. The appeal was filed by the Revenue, and the cross-objection (CO) by the assessee, Viacom 18 Media Pvt. Ltd., arising out of the assessment proceedings initially conducted in the name of M/s Prism TV Pvt. Ltd.
M/s Prism TV Pvt. Ltd. filed its income tax return on 29 November 2014, declaring a total loss of Rs. 107.54 crore. The return was processed under Section 143(1) of the Income Tax Act, 1961, and later selected for scrutiny. The Deputy Commissioner of Income Tax (DCIT)-14(1), Hyderabad, issued a notice under Section 143(2) dated 28 August 2015. Subsequently, the assessee submitted details and attended hearings. During the course of assessment, by a letter dated 24 October 2016, Prism TV Pvt. Ltd. informed the Assessing Officer (AO) about its merger with Viacom 18 Media Pvt. Ltd., approved by the Bombay High Court order dated 12 August 2016, effective from 1 April 2015. As a result, Prism TV Pvt. Ltd. ceased to exist.
